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Greater-Than-Class C Low-Level Radioactive Waste EIS

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This project was funded by the Washington, DC headquarters of
the Department of Energy Office of Environmental Management. Funds
were provided for American Indian tribal representatives to provide
official analysis and assessments of cultural impacts that
potentially could derive from the proposed waste management
isolation facility. The study provided American Indian tribal
inputs to a national Programmatic Environmental Impact Assessment
(PEIS) of establishing an isolation facility for Great Than Class C
(GTCC) and GTCC – like radioactive waste. The PEIS considered
establishing the new isolation facility at (1) Hanford Site, (2)
Los Alamos National Lab, (3) the Nevada Test Site, (4) Idaho
National Lab, (5) Oak Ridge Reservation, and (6) Savannah River
Site. American Indian studies were facilitated at the first three
of these potential GTCC isolation locations.

There is a history of formal government-to-government
consultation at Hanford, Los Alamos National Lab, and the Nevada
Test Site, so this was a foundation of involving tribal governments
and their representatives at each of these DOE facilities. At the
remaining facilities either the DOE did not believe there were
culturally affiliated tribes or the tribes decline to participate
in the GRCC PEIS.

GTCC LLRW is defines as needing special isolation because it
exceeds the concentration limits of radionuclides for LLRW
established by Congress. GTCC is generally generated by National
Labs but is comes from power plants and medical facilities. It is
generally classified as (1) activated metals, (2) sealed sources,
and (3) other wastes.

Richard Stoffle (Professor, School of Anthropology, University
of Arizona) and Richard Arnold (Chairman, Pahrump Paiute Tribe)
were contracted by the Washington, DC Office of the Environmental
Management who headed up the PEIS. Both Stoffle and Arnold had
extensive experience creating settings for tribes to quickly
participate in Environmental Impact Assessments so that tribal
concerns could be considered in an EIS. Stoffle and Arnold had
previously worked with the tribes at Hanford, Los Alamos, and the
NTS. Arnold was the official spokesperson for the consulting tribes
at the NTS, who call themselves the Consolidated Group of Tribes
and Organizations. Stoffle and Arnold were to create a
participation setting and facilitate the production of text that
was reflective of the tribal concerns.

Representatives of all potentially involved tribes were provided
with an orientation to the GTCC PEIS study and provided time to
discuss the opportunity with their tribal governments deciding
whether or not to participate. Participation of tribal
representatives involved funds provided by the DOE. All
participating tribes provided text for inclusion into the PEIS. A
tribal condition of participation was that tribal text could
neither be edited nor summarized by the DOE, but instead what the
tribal governments approved would be directly added to the GTCC
PEIS. This stipulation was agreed to by the DOE and at each
facility the consulting tribes wrote text that was subsequently
included in the final PEIS.

A special feature of the negotiations to participate was that
tribes would have the right to provide evaluations of any aspects
of environmental assessment. Often tribes are limited to cultural
resource responses and denied the right to comment on others
aspects of the assessment.

Confedered Tribes of the Umatilla Indian Reservation; Stoffle, Richard W.; Arnold, Richard A.; Confederated Tribes of the Umatilla Indian Reservation; Bureau of Applied Research in Anthropology, University of Arizona; Consolidated Group of Tribes and Organizations(Department of Energy, 2009-06)

The Wanapum Tribe; Stoffle, Richard; Arnold, Richard; The Wanapum Tribe; Bureau of Applied Research in Anthropology, University of Arizona; Consolidated Group of Tribes and Organizations(Department of Energy, 2009-06)

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